Williams v. United States
- Kimba Wood
- 1:19-cv-11402
- U.S. District Court · Southern District of New York
- 4
In Williams v. United States, Judge Wood denied Curtis Williams’s sentence-challenge motion because Dimaya and Davis did not apply.
Curtis Williams’s federal firearm conviction and sentence were left undisturbed; the United States prevailed on the § 2255 challenge.
What happened
In Williams v. United States, Curtis Williams challenged his firearm conviction after pleading guilty to drug and firearm offenses. The court had sentenced him to 180 months in prison.
Williams argued that two Supreme Court decisions, Dimaya and Davis, made his firearm conviction invalid. His firearm conviction was based on using and carrying a firearm during and in relation to a drug-trafficking crime, specifically his drug conspiracy.
Judge Kimba M. Wood denied Williams’s motion because those Supreme Court decisions invalidated only a definition covering crimes of violence, not the separate definition covering drug-trafficking crimes. The court also denied a certificate of appealability and directed the Clerk to close the case.
The detailed version
- Williams v. United States · No. 1:19-cv-11402
- Kimba Wood
- July 16, 2020
Background
Curtis Williams pleaded guilty to conspiring to distribute and possess with intent to distribute 28 grams or more of cocaine base, in violation of 21 U.S.C. §§ 846 and 841(b)(1)(B). He also pleaded guilty to using and carrying a firearm during and in relation to a drug-trafficking crime, with the firearm brandished and discharged, in violation of 18 U.S.C. § 924(c). The court sentenced him to a total of 180 months in prison.
Williams filed a motion under 28 U.S.C. § 2255, a procedure allowing a federal prisoner to challenge a conviction or sentence on specified constitutional or legal grounds. He initially filed the motion without a lawyer. The court appointed Attorney Ezra Spilke to assist him in amending the motion, but Spilke determined that no meritorious arguments could be added and declined to file an amended motion. The government responded to Williams’s original motion.
Williams’s Argument
Williams argued that his conviction under § 924(c) was invalid under the Supreme Court’s decisions in Sessions v. Dimaya and United States v. Davis.
Section 924(c) prohibits using or carrying a firearm during and in relation to a crime of violence or drug-trafficking crime, or possessing a firearm in furtherance of such a crime. The statute separately defines “drug-trafficking crime” as a felony punishable under specified federal drug laws. It also defines “crime of violence” through an elements clause and a residual clause.
Dimaya and Davis held that residual clauses in the definitions of crimes of violence were unconstitutionally vague. The court explained that those decisions did not invalidate § 924(c)’s separate definition of a drug-trafficking crime.
Court’s Analysis
Williams’s § 924(c) conviction was based on carrying and using a firearm during and in relation to the drug-trafficking crime of his narcotics conspiracy. It was not based on a predicate crime of violence. Because his conviction rested on a drug-trafficking crime, rather than the challenged residual clause for crimes of violence, Dimaya and Davis did not provide a basis to disturb his conviction or sentence.
Ruling
The court denied Williams’s § 2255 motion. It also determined that he had not made a substantial showing that a constitutional right had been denied, so it directed that no certificate of appealability issue. The Clerk of Court was directed to close the case.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.